Lobbying Governance
| Overall Assessment | Analysis | Score |
|---|---|---|
| Limited |
Sulzer discloses only limited information on how it governs lobbying activities. The company states that its “Sulzer Membership and Contributions Directive” is intended “to ensure full compliance with all applicable laws and legislation regarding anti-bribery and anti-corruption by defining the criteria and processes relating to the personal and financial engagement of Sulzer and our employees in organizations and activities outside of the Sulzer companies,” and it adds that “making political contributions is prohibited unless they are made in Switzerland and approved by the CEO in advance.” This indicates that at least one approval and oversight step—sign-off by the CEO—exists for political engagement. However, beyond listing memberships in bodies such as the “American Petroleum Institute (API)” and “Swiss carbon removal platform Associations,” the disclosure offers no explanation of how Sulzer monitors or evaluates whether its direct or indirect lobbying, especially on climate matters, aligns with its stated policies, nor does it identify any board committee or individual responsible for ongoing oversight beyond the CEO’s approval of Swiss political donations. We found no evidence of a systematic process for reviewing trade-association positions, no climate-lobbying alignment policy, and no publicly available lobbying-alignment report. Consequently, the publicly available information points only to a narrow, donation-focused approval mechanism and does not demonstrate a broader governance framework for climate-related lobbying.
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D |